Lee v. United States of America

Filing 39

ORDER granting ECF No. 37 Unopposed Motion. Joint Status Report due by 5/20/2016. Signed by Magistrate Judge Peggy A. Leen on 5/20/2016. (Copies have been distributed pursuant to the NEF - KR)

Case 2:14-cv-00606-RCJ-PAL Document 37 Filed 05/18/16 Page 1 of 2

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BAILUS COOK & KELESIS, LTD.
GEORGE P. KELESIS, ESQ. (0069)
MARK B. BAILUS, ESQ. (2284)
517 S. Ninth Street
Las Vegas, Nevada 89101
Phone: [phone]
Fax: [phone]
E-mail: [e-mail]

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EDWARD O.C. ORD, ESQ. (Pro Hac Vice)
California State Bar No. 52123
ORD & NORMAN
233 Sansome Street, Suite 1111
San Francisco, CA 94104

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Attorneys for Theodore Lee
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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****

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THEODORE LEE,

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Plaintiff,

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v.

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UNITED STATES OF AMERICA,

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Defendant.
_______________________________________

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Case No. 2:14-cv-00606-RCJ-PAL

And related Crossclaims.

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UNOPPOSED MOTION TO
EXTEND JOINT STATUS
REPORT DEADLINE

COMES NOW, Plaintiff THEODORE LEE, by and through his undersigned counsel and
hereby moves this Court to issue an order that the deadline to complete the joint status report set
forth in Order (Doc. #36) be continued from May 19, 2016 to and including May 20, 2016.
Plaintiff sets forth the following in support of this motion:
1. Plaintiff requests additional time to finalize his portion of the joint status report currently
due on May 19, 2016. As such, Plaintiff is requesting an extension of the deadline from May 19,
2016 to May 20, 2016 to file the joint status report.
2. The United States does not oppose Plaintiff’s motion to extend deadline for the joint
status report to May 20, 2016, but is nevertheless prepared to meet the current existing deadline.

Case 2:14-cv-00606-RCJ-PAL Document 37 Filed 05/18/16 Page 2 of 2

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3. This motion is not being submitted for the purposes of delay but in order to insure that the
Plaintiff has a full and fair opportunity to preserve his claim for a refund of taxes.
DATED this 18th day of May, 2016.
BAILUS COOK & KELESIS, LTD.

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/s/ Mark B. Bailus
Mark B. Bailus, Esq. (2284)
517 S. Ninth Street
Las Vegas, Nevada 89101
Counsel for Plaintiff, Theodore F. Lee

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Page 2 of 2

Case 2:14-cv-00606-RCJ-PAL Document 37-1 Filed 05/18/16 Page 1 of 1

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BAILUS COOK & KELESIS, LTD.
GEORGE P. KELESIS, ESQ. (0069)
MARK B. BAILUS, ESQ. (2284)
517 S. Ninth Street
Las Vegas, Nevada 89101
Phone: [phone]
Fax: [phone]
E-mail: [e-mail]

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EDWARD O.C. ORD, ESQ. (Pro Hac Vice)
California State Bar No. 52123
ORD & NORMAN
233 Sansome Street, Suite 1111
San Francisco, CA 94104

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Attorneys for Theodore Lee
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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****

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THEODORE LEE,

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Plaintiff,

Case No. 2:14-cv-00606-RCJ-PAL

v.

[PROPOSED]
ORDER GRANTING UNOPPOSED
MOTION TO EXTEND JOINT
STATUS REPORT DEADLINE

UNITED STATES OF AMERICA,

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Defendant.
_______________________________________

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And related Crossclaims.

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The Court having read and considered the Unopposed Motion to Extend Joint Status
Report Deadline (“Motion”), and for good cause shown:
IT IS HEREBY ORDERED that the Motion is GRANTED.
IT IS FURTHER ORDERED that the deadline to complete the Joint Status Report is
extended to and including May 20, 2016.
DATED this 20th day of May, 2016.

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UNITED STATES MAGISTRATE JUDGE